Wednesday, September 19, 2012

2012 CSSS Presentations – CFATS at Educational Institutions

This is the another in a series of blog posts about presentations made at the recent 2012 Chemical Sector Security Summit. The first in the series dealt with the problems associated with the presentations in general. The subsequent posts will deal with the information provided in the slide presentations. The published presentations only provide the outline, I’ll try to fill in what information that I can from other sources or my best guesses.

This post will look at the application of the CFATS program at educational institutions. The presentation was made by Brad Huntsman of ISCD. Since the first draft of the CFATS regulations DHS has made it clear that they expected that there would be portions of educational facilities that would fall under the CFATS definition of a high-risk chemical facility, including laboratories and physical plant operations. This brief presentation looks at how many such facilities actually made it onto the current list of high-risk chemical facilities regulated under CFATS.


The CFATS regulations require any facility that has had in the last 60-days an inventory of any of 300+ DHS chemicals of interest (COI; Appendix A, 6 CFR Part 27) in excess of the listed screening threshold quantity (STQ) to submit a Top Screen to provide DHS with the initial information needed to determine if a facility could potentially be regulated under the CFATS program. Slide # 3 of the presentation notes that the following areas of educational facilities could be affected by this Top Screen submission requirement (Note: This is not an exhaustive list):

• Chemistry labs;
• Research facilities;
• Field houses;
• Pool complexes; and
• Agricultural, medical, and other campus facilities

Slide #4 provides the following data on the number of Top Screen submissions and subsequent status under the CFATS rules:

• 324 Top Screen submissions;
• 60 Regulated high-risk chemical facilities; and
• 8 Pending final status determination.

After each potentially regulated facility submits a subsequent Security Vulnerability Assessment (SVA) ISCD makes a final determination if the facility is a covered facility and places it into one of four risk tiers ranking its potential risk for terrorist attack; Tier 1 is the highest tier ranking. Slide #4 also provides data on the tier rankings of the 60 regulated educational facilities.

• 1 Tier 1 facility;
• 17 Tier 2 facilities;
• 6 Tier 3 facilities; and
• 36 Tier 4 facilities.

There is nothing in the presentation that explains why there is a Tier 1 facility on this list, but I would suspect that it is due to the presence of a large amount of a toxic inhalation hazard chemical (probably chlorine or anhydrous ammonia) at a campus support facility though it could be due to the presence of relatively small amounts of actual chemical weapons grade materials at a research lab. The Tier 4 facilities are probably due to the significant presence of theft-diversion chemicals in campus labs or research facilities; these would be due to chemicals that could be used to make improvised explosives or chemical weapons.

Defining Covered Facilities

Because an educational institution is regulated under CFATS does not mean that the entire facility is placed under strict security controls. This would be patently untenable for an entire college or university to be placed under the type security measures necessary to comply with the Risk-Based Performance Standards for high-risk chemical facilities.

As do all chemical facilities, these schools have the option of just what portion of their campus will be included in the boundaries of the reported facility. In fact, the 60 CFATS covered facilities are located at only 45 different schools. This means that some number of schools have multiple covered facilities within their campus.

Educational Security Measures?

It does not appear that Mr. Huntsman provided any information about how the Department expected these facilities to go about adequately security their facilities. The presentation includes a generic page that deals with “CFATS Outreach to Colleges and Universities” but it provides no real information other than mentioning “DHS has created outreach materials” (a tri-fold brochure that can be accessed on the CFATS Knowledge Center web page. Sorry no permanent link is available; go to ‘page 2’ of the Documentation section at the bottom left of the page) for such institutions.

Because of the problems that ISCD is having with their Site Security Plan approval process, I would suspect that, other than the one Tier 1 facility, they have not given a lot of thought to the process of how schools should go about securing their high-risk chemical facilities.

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